Australia should consider introducing a national workers’ compensation scheme instead of a “patchwork” of programs, according to Aon.

The global broker’s workplace risk director Gary McMullen says a new approach is needed to address failings caused by the current set-up.

“Australia’s patchwork of 11 different workers’ compensation schemes has created a deeply unequal, flawed system, leaving employees and employers alike at a significant disadvantage,” Mr McMullen writes in a paper.

“To say the Australian landscape for workers’ compensation today is ‘fractured’ is a gross understatement. Australia’s current workers’ compensation situation is awash with inequality and unfairness. This includes different criteria for determining liability on claims and also the amount of compensation payable.”

The maximum award for a permanent impairment claim can vary from $713,000 in Victoria to $619,000 in SA, $430,000 in Tasmania and $261,000 in the ACT.

In some cases, staff working for the same employer at the same location may have vastly different entitlements for identical injuries, underscoring the need for a more consistent approach, Mr McMullen says.

“This is simply because some employees for a group employer are insured under a generous Comcare scheme and others, working in a subsidiary of the group employer, are not covered by Comcare and thus have lesser entitlements.”

The rise of mental health claims has added to the “divergence” in workplace protection.

Citing Victoria, which has revised eligibility criteria for mental injury compensation, Mr McMullen says: “These changes have further complicated the landscape for Victorian employers. The divergence in workers’ compensation entitlements between employees under different schemes, such as Comcare, has created inequities.”

The federal government’s announcement in June that an independent panel will review Comcare “presents an opportunity for key stakeholders to advocate for a system that serves everyone equitably”, Mr McMullen says.

Comcare covers more than 470,000 people, providing rehabilitation and workers’ compensation arrangements to employees of the Commonwealth government, the ACT government and some private corporations.

“As discussions around a national workers’ compensation framework gain momentum, it is crucial for policymakers and businesses to actively engage in this dialogue,” Mr McMullen says.